David Shuster

David Shuster

JD, LL.M., Principal, Director of Tax Controversy Services

One Liberty Plaza
165 Broadway, Floor 21
New York, NY 10006
p 212.842.7583
f  212.897.6488

David Shuster is a Principal at Friedman LLP, with more than 25 years of tax controversy experience. He advises, represents and defends clients in their controversies with the IRS and the state taxing authorities. Dave also consults with corporations, partnerships, private foundations, public charities and individuals on federal and state tax planning and compliance.

Beginning his career at the United States Department of Justice, Dave was appellate counsel to the government in a wide variety of tax cases. There, he briefed and orally argued cases in nearly all of the federal circuit courts of appeals. He also advised and assisted the Solicitor General’s Office in its Supreme Court litigation. Subsequently, as a tax partner at an international law firm, Dave focused on tax controversy, planning and compliance issues.


His experience includes:

  • Advising and representing individuals and entities in all aspects of federal and state tax audits and administrative proceedings and providing litigation support
  • Pursuing Private Letter Ruling, Freedom of Information Act, and IRS Collection Due Process Hearing requests, IRS Appeals protests, NYS Bureau of Conciliation and Mediation Service requests, and drafting NYS Tax Appeals Tribunal briefs, and petitions and other documents for filing in other states’ administrative appeals venues and in the United States Tax Court
  • Handling federal and state voluntary disclosures including those having FBAR and other foreign asset aspects involving use of OVDP, streamlined procedures, and delinquent return submission procedures
  • Responding to all types of tax notices including those involving unreported income, compliance penalties, enforced collection activity (liens, levies, warrants), refunds, and residency and nexus issues
  • Obtaining, and seeking reinstatement of, tax exempt status for private foundations and public charities

As a frequently sought after thought leader, Dave has served as a guest panelist for several speaking engagements including:  

  • Representing Taxpayers Before IRS Appeals With Respect to Penalties Resulting from the Failure to Report Foreign Income or Assets, International Tax Enforcement Update, Hackensack, NJ, June 2018
  • Waking Up the Dead: Reopening that Asessment Your Client Thought Was Final, 9th Annual NYU Tax Controversy Forum, New York, NY, June 2017
  • Challenging IRS Penalties, 7th Annual NYU Tax Controversy Forum, New York, NY, June 2015
  • Tax Controversy: Handling Audits, Appeals, Litigation, and Collections for Clients, The Knowledge Group, Live Webinar, February 2015

Dave has been frequently quoted throughout the media across several outlets including: 

  • U.S News and World Report, Accounting Today, Law 360, Vice News, and Times of Israel, among others
  • Backyard Sports Cares – Board Member, Treasurer
  • Scarsdale Schools Education Foundation – Board Member, Treasurer
  • Beach Point Club, Mamaroneck, NY – Finance Committee, Former Board Member
  • Long Island Business News – Leadership in Law Award Recipient, In-House Counsel, 2011